LWD, Inc. - Executive Summary |
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Risk Management Plan (RMP) Executive Summary Accidental Release Prevention and Emergency Response Policies LWD, Inc. has operated safely since 1977 to provide solutions to society's hazardous waste management needs through innovative, safe, and environmentally sound treatment processes. LWD's objectives include fostering a safe, positive working environment that is conducive to innovation. Chemical safety is a number one priority with support from the highest level of management. The Environmental and Safety Department reports directly to the Vice President, who reports directly to the CEO and President. Thus Senior Management promotes safety and environmental compliance. There are many programs in place to promote chemical safety and the facility is usually subjected to at least four surprise inspections a year by different governmental agencies. The hazardous waste incineration industry is one of the most highly regulated in the country. Not only does LWD comply wit h numerous Environmental Protection Agency (EPA) and Resource Conservation and Recovery Act (RCRA) programs such as Risk Management Plan (RMP), it also complies with the Department of Transportation (DOT) programs, Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) programs, the Emergency Planning and Community Right to Know Act (EPCRA) programs, State and Local Fire Code programs, and the National Electrical Code programs. To even further promote chemical safety, the Occupational Safety and Health Administration (OSHA) programs Process Safety Management (PSM) and Hazardous Waste Operations and Emergency Response (HAZWOPER) also regulates the facility. As part of the RMP and PSM programs, LWD's chemical safety program begins with quality assurance for all equipment, piping systems, storage tanks, relief and vent systems, controls, emergency systems, and pumps. This guarantees that these units meet all applicable design codes and specifications. Thi s program includes periodic testing based on the manufacturer's specifications and professional engineering analysis of the specific use in the process. Documentation of the codes and specifications form the basis of the process information. An employee participation plan ensures that employees are involved throughout the program adding experience and a working knowledge of the process to the safety suggestions. This combination of engineering, process information, and analysis is supplemented by trained employees working with specific operating instructions to address all contingencies to ensure operations are conducted within safe limits. The facility has layers of protection built into its process. The first level includes the personnel. Trained operators are working with operating instructions and process safety information to keep the process operation safe and in environmental compliance. The second level involves technical controls. Control systems and instrumenta tion provide the tools to maintain the process within these limits. Process safety control systems include: relief vents; check valves; manual shutoffs; interlocks; alarms; a keyed bypass; grounding equipment; and a purge system. Monitoring and detection systems include: process area monitors; personal monitors; portable monitors; camera systems; special indicator paint; and daily inspections by trained safety personnel. In addition, each shift has a designated trained supervisor to be responsible for environmental and safety compliance. To supplement and enhance these on-site programs, LWD participates in several organizations which promote safe environmental and chemical practices. As a member of the Calvert City Industrial Mutual Aid Program (CIMAP) it can rely on pooled resources from surrounding plants and communities. The Company regularly participates in the Local Emergency Planning Committee (LEPC) emergency response drills with outside emergency responders and regu larly performs in house emergency drills. Local Disaster and Emergency Services (DES) personnel, LEPC members, and others regularly tour the facility to familiarize themselves with the facility and its hazardous materials, equipment, layout, and personnel. LWD is also a member of the Coalition for Responsible Waste Incineration in which detailed safety and compliance information is shared to further promote the safe and effective thermal treatment of hazardous wastes. The Stationary Source and Regulated Substances Handled The facility, which is located in Calvert City, KY, includes three hazardous waste incinerators and affiliated hazardous waste storage facilities. Many of the chemical safety procedures mentioned previously are designed specifically for chemicals handled by the facility, which include familiar household products such as paints, adhesives, herbicides, pesticides, cleaners, and solvents. Specifically, the Risk Management Chemicals at the LWD facility include Hydrogen Fluoride, Formaldehyde, Isobutane, Butadiene and Vinyl Methyl Ether. Many of these items would be immediately recognizable by the average individual if trade names were used instead of chemical names. The major difference is the volume of waste that a household would produce versus an industrial application. Where a household would have a gallon of drain cleaner stored in a safe place away from the reach of small children, LWD would have hundreds of gallons stored in a safe place away from persons unaware of the hazards. Chemicals such as hydrogen fluoride, commonly used as a wheel cleaner or an oven cleaner, and isobutane, which is a common non-CFC aerosol propellant, are included in the release scenarios for the Risk Management Plan. Just as in a household, these chemicals are not always present. Because LWD is a commercial facility, the amount of material on site, if any, is dependent upon the manufacturer (or generator) at any given time. Worst Case Release Scenar ios and The Alternative Release Scenarios The toxic worst case scenario chemical examined is Hydrogen Fluoride (HF). Using the methods specified by EPA, the vaporized HF would exceed the plant's boundaries. The worst case scenario as defined by EPA for the RMP rule does not allow for any active action to prevent the release. It also assumes worst case conditions for the release in its calculations. There are many active control systems, described previously, to prevent an incident from occurring. The main control and safety systems in place to prevent such an incident include: pressure testing the product line before each use; a continuous process area monitor; personal monitors while hooking and unhooking the product lines; special indicator paint; DOT inspections of the container in which the material is received; pressure vents; check valves; and continuous camera monitoring of the container. Although these safety systems are in place, the worst case scenario does not take into account any of the responses which may be performed by the trained operators. The flammable worst case scenario chemical examined is Isobutane. Using the methods specified by EPA, the distance to a 1.0 psi overpressure endpoint would exceed the plant's boundaries. As mentioned earlier, the worst case scenario as defined by EPA for the RMP rule does not allow for any active action to prevent the release. It also assumes worst case conditions for the release in its calculations. There are many active control systems, described previously, to prevent an incident from occurring. The main control and safety systems in place to prevent such an incident include: a daily visual inspection of the product line; DOT inspections of the container in which the material is received; manual shutoffs; automatic shutoffs; interlocks; relief vents; check valves; and grounding equipment. Although these safety systems are in place, the worst case scenario does not take into account a ny of the responses that the trained operators may perform. The alternate case scenarios include two toxic and one flammable release scenario of HF, Formaldehyde and Isobutane, respectively. Using EPA's Guidance and Reference Tables/Equations, the endpoints exceed the plant boundaries, but do not exceed the industrial complex in which the facility is located and do not affect any residential area. Passive mitigation was used in the alternative case for formaldehyde since the storage tanks have secondary containment. Although there are active controls and measures directed at preventing and controlling the consequences of such releases, no credit was taken for active mitigation methods in evaluating these alternative scenarios. General Accident Release Prevention Program and Chemical Specific Prevention Steps LWD has a general accident release prevention program which includes extensive classroom and on the job training for all its employees. This training also requires each employee take a competency exam. This program instructs the employee in safe working practices, ranging from the proper operation of a fork lift to the process operations. Monthly training on various topics, ranging from sampling of materials to hot work permits, keeps safety and environmental compliance paramount in the minds of the employees. All employees are required to attend an annual 8 hour refresher training class with competency testing. On-site contractors, whose function would involve a process, are also required to complete classroom and on the job training for chemical safety. Chemical specific prevention steps include the process and procedures outlined for that chemical or operation. These were described earlier and include the following examples for the specific chemical HF: pressure testing the product line before each use; a continuous process area monitor; personal monitors while hooking and unhooking the product lines; special indicator pain t; DOT inspections of the container in which the material is received; pressure vents; check valves; and continuous camera monitoring of the container. Although these safety systems are in place, the worst case scenario does not take into account any of the responses that the trained operators may implement. The Five-Year Accident History The five-year accident history for the facility includes one reportable incident under RMP. The incident occurred in 1997 when an employee did not properly close a valve and material leaked causing a flash fire from which one employee received burns. Operating procedures were revised and additional training was conducted to prevent any reoccurrence The incident was attributed to human error. The release did not result in any off-site consequences, nor has the facility ever had any RMP release that resulted in off-site consequences. The Emergency Response Program In compliance with the RMP rule and Part 270.25(a)(7) and Subpart D of Part 264 (264.50 through 56) of the Resource Conservation and Recovery Act regulation, LWD has maintained a Contingency Plan detailing procedures to "minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water". This contingency plan provides an explicit description of the response procedures to be implemented in an emergency situation which will protect the public, workers on the site, and the environment. Planned Changes to Improve Safety LWD is committed to safely providing solutions to society's hazardous waste management needs. The programs in place will continue to be improved as technology and science improves. We are committed to making chemical safety a number one priority through safe-operating procedures, trained personnel, and environmentally sound treatment processes. Participation in the various environmental and safety focused associations provides LWD with the technology transfer abilities to continuously look for improvements in its control and safety systems. Annual visits to other facilities also enable the facility to examine and review new safety systems for our specific application. |